For the 2019 filing season, the IRS projects that more taxpayers than ever will file and owe. Many will be able to pay – but a lot of them will need to make other arrangements because they can’t pay their full tax bills to the IRS. When taxpayers can’t pay their tax bills, they have…
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CFC Partner's E&P is Increased by Domestic Partnership's Section 951 (a) Income Inclusions
The Tax Court has concluded that for the years at issue (2007 - 2010), the earnings and profits (E&P) of the upper tier controlled foreign corporation (CFC) partner of a domestic partnership had to be increased as a result of the partnership's Code Sec. 951(a) income inclusions. (Eaton Corporation and Subsidiaries, (2019) 152 TC No.…
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US S.C. To Decide Whether States Can Tax Out-of-State & Foreign Trusts
More than $120 billion of our nation's income flows through trusts, and the Supreme Court will hear a case that may clarify how much states are able to tax. According to Ostrow Reisin Berk & Abrams (via Mondaq) in April, the Supreme Court of the United States will hear an appeal against North Carolina's practice of…
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IRS Reports Increased in 2018 Whistleblowers Awards
The Internal Revenue Service (IRS) has reported in its WhistleblowerProgram Fiscal Year 2018 Annual Report to Congress that information provided to the program in the past tax year has led to the collection of USD1.44 billion in taxes, penalties and interest from those attempting to cheat the system. Further, Lee Martin, Dir. of the IRS…
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